FDIC Law, Regulations, Related Acts

4000 - Advisory Opinions

Moratorium on Conversion Transactions Imposed by Provisions of
FIRREA

FDIC--89--38

November 8, 1989

Douglas H. Jones, Deputy General Counsel

In response to your October 26 letter, we agree with your assessment
that neither the Financial Institutions Reform, Recovery, and
Enforcement Act of 1989 ("FIRREA") nor any other current
provision of Federal law would compel a Savings Association Insurance
Fund ("SAIF") member savings association that converts to a bank
charter during the moratorium on conversion transactions imposed by the
provisions of FIRREA, but remains a SAIF member, to change its status
to a Bank Insurance Fund member after the moratorium
expires.